in the European Union Regulation against Deforestation (EUDR)
The role of wood
The role of timber in the European Union Regulation against Deforestation (EUDR)
Wood is one of the priority raw materials identified by the EUDR due to its direct impact on global deforestation. This regulation aims to ensure that products produced or marketed in and from the European Union have no trace of deforestation or forest conversion throughout the value chain.
What products are covered by the EUDR?
-
Relevant products are those listed in Annex I of the EUDR. This annex defines the applicability of the regulation by classifying the relevant products according to their Harmonized System or HS code.
Annex 1 -
The products concerned range from basic forms of wood such as firewood, charcoal or raw wood, to processed products such as panels, veneers, furniture, prefabricated buildings and joinery. Also, some publishing and paper products, as well as furniture with wood components, are relevant products.
-
The inclusion of these products implies that all operators who introduce them into the European market, trade within it or export them from the European Union must demonstrate, through a due diligence system, that they have been produced without causing deforestation and in compliance with the laws of the country of origin.
What about packaging material?
Wood products used as packaging have a specific treatment within the regulation.
Thus, wooden pallets, cardboard boxes and any similar product will be exempted from complying with the requirements of the standard as long as their use is exclusively as packaging to hold, protect or transport another product. On the other hand, if these products are introduced into the EU market as commercial goods in their own right, they fall within the scope of the regulation and must comply with the requirements of the standard.
What about products made from recycled materials?
Recycled products are those that have completed their life cycle and are reused as raw material to manufacture new products, either similar to the original or completely different.
When a product is composed exclusively of wood derivatives or recycled wood, it is not subject to EUDR due diligence obligations. However, in the case of composite products combining recycled and non-recycled wood, the parts corresponding to the virgin material will need to be declared and justified.
In these cases, the operator must have internal traceability mechanisms in place to segregate, identify and properly document the origin and proportion of each type of material.
What changes with respect to the European Timber Regulation (EUTR)?
The European Timber Regulation (EUTR), in force since 2013, requires timber placed on the EU market to be of legal origin and obliges operators to implement due diligence systems.
With the entry into application of the EUDR, the EUTR will be repealed. However, a transitional period is established: timber products defined in Article 2.a of Regulation (EU) No. 995/2010 (EUTR) and produced before June 29, 2023 will continue to be subject to the provisions of the EUTR if placed on the market between December 30, 2025 and December 31, 2028. As of December 31, 2028.From December 31, 2028, all wood products will have to comply with the requirements of Article 3 of the EUDR, regardless of their date of production.
Unlike the EUTR, the EUDR adds a new criterion: the absence of deforestation or ecosystem conversion from December 31, 2020. It also extends the scope to more products and strengthens traceability requirements. Therefore, even if there is previous experience with the EUTR, it will be necessary to review and adapt existing systems to ensure compliance with the new regulatory framework.
What if the products are certified?
The EUDR has not identified any certificate that, on its own, guarantees compliance.
However, certifications such as FSC or PEFC can be considered as complementary evidence within the due diligence system, as long as they include criteria aligned with EUDR requirements. While these certificates do not exempt from compliance, they can reinforce the credibility of the analysis performed by the economic operator.
How can we support you?
Do you have any question regarding our services? Let us know! We will be glad to help.